Mr. Bump, however, surmounts this difficulty by stat to the constitution of the English courts and to remedies, which are of interest as matters of legal informa-ing a priticiple applicable to a particular case, and then tion and history to the American lawyer, but not so essential to him as to the English lawyer. The present edition furnishes all the authorities up to the time of its issue. And what Blackstone and Kent took several volumes to discuss and illustrate, Broom has condensed into a single volume of rare merits. The volume is thus as full of legal information and legal principles as a work can well be. It is in fact❘ a splendid specimen of legal condensation; and although it cannot supply the place of Kent's commentaries in this country, or entirely supersede Blackstone's commentaries, it must always be a welcome and a useful lego-literary guest in the library of both the profession and the laity. A Treatise upon Conveyances made by Debtors to defraud citing the authorities, which, by inspection, will show the law within the specified jurisdiction "so that each practitioner can tell at a glance whether any proposition is accepted in his own State." This method of writing a treatise has not only the merit of utility, but is also growing in favor among all professions as being the true, scientific method of presenting a subject. The author avoids, as much as possible, theories and opinions and views which are personal, and simply reflects, in an impersonal way, the legal phenomena which he sees. At first it is somewhat humiliating to an author thus to keep his own private views in the background, but he soon forgets this personal feeling in the impersonal, and dwells only in the consciousness that he is acquiring law, and arranging it for others in symmetrical, convenient and desirable form, that he is the happy medium of the transmission, concentration and utilization of the light of legal knowledge. It would be difficult to think of any thing which Mr. Bump has left out of his treatise pertaining to the precise point treated. Even a chapter on "International Law" is inserted, showing the effect of the principles of international law upon conveyances to defraud creditors. The work is supplied with references to all the cases both English and American, and the citations are brought down to a very recent period; and the result is a complete treatise upon a difficult special subject which the profession will do well to avail itself of. A Treatise on Mental Unsoundness, embracing a general view of psychological law, by Francis Wharton, LL. D., vol. 1. Philadelphia: Kay & Brother, 1872. The discovery of the "physical basis" of life and mind, and the intimate relation, correlation, correspondence and sympathy of the physical with the mental and moral, have resulted in the modification of the treatment of the insane and of criminals. What was once regarded as proceeding from a responsible will, and an evil intention, is now found by scientific inves The increasing magnitude of the litigation on special branches of the law is naturally attended with a corresponding increase of the reports upon those specialties. To go through the great mass of adjudications and cull those which are of a kindred nature, and deduce therefrom the law relative to a special subject, is a task not more easy to an author than the results of it are desirable and valuable to the legal profession. How a single statute like that of 27th Elizabeth or of 15th Elizabeth could give rise to such a prodigious amount of litigation and adjudication, would appear inexplicable to any but the student of legal history and the observer of courts, laws, lawyers and clients. But in law, as in every thing else, what was once a mole hill becomes a mountain by successive additions and integrations; what was once a specialty becomes a department, and the specialty of to-day becomes the department of to-morrow, which, in turn, is divided into special branches, and so on ad infinitum. For a long time, the treatise of Roberts on Fraudulent Conveyances in general, was regarded as quite sufficient. Then "May's Voluntary and Fraudulent Conveyances," and "Hunt's Fraudulent Conveyances"❘tigation, to proceed, in many cases, from physical and appeared, both of which were occupied with the general subject of fraudulent conveyances. And now Mr. Bump, perceiving the extent and variety of the decisions upon this general subject, has very wisely concluded to bring out a work on the special subject of "Conveyances to Defraud Creditors." The author did not discover any want of material in the execution of his design, and has produced a work which the profession very much needed. The result of his labors is a volume "presenting the law in a compact, accessible shape," as the author himself claims, and justifying our expectations of what such a work would be at the hands of a law writer of Mr. Bump's ability and experience in the presentation of special legal subjects. The first chapter is on the "History of the law of Fraudulent Conveyances" which the author exhibits both good taste and good judgment in including in the treatise, especially in view of the fact that no branch or department of jurisprudence is now considered well studied or known or treated, unless, in part, historically. The difficulties which are to be met with in the preparation of a work of this character are shown in nearly every subsequent chapter. The State statutes, although copied substantially from the English statutes of 13th Eliz. are, many of them, just enough different to occasion discrepancies in the decisions of the State courts. moral causes entirely or partially beyond the control of the individual. The scientific view of mental unsoundness, and the legal view, have not yet been reconciled completely. The legal view is old, and has precedence in respect to time over the scientific view. But it is always the province of jurisprudence to avail itself of the light of science and of all experience in the adoption of principles and their application. The law is the "science of sciences" and, therefore, the law can go no higher than the aggregate of sciences, and must always depend upon these for its facts, its data, its materials for judgment. At the close of the eighteenth century insanity was scarcely recognized among the medical faculty as a disease, and much less as an excuse for crime. But the developments of the last half century in psychology, in physiology and in biology, have shown how intimate is the connection between the functions of the body and of the mind, how complete is the interdependence and how strong is the sympathy. And it has been found that medical treatment will operate successfully, in a large majority of cases, to relieve and even cure an insane patient. The study of mental unsoundness has become an interesting and important department of science; and the courts have found it necessary to admit the results of medical experiment and scientific observa tion in order to ascertain the limit and nature of human responsibility for inhuman acts. The discovery of a cause for crime, other than a responsible will and a controllable desire and intention, at first led to the adoption of an extreme view, and the courts had to contend with a sentimental humanitarianism or a psychological romanticism which would make all crime irrational and all criminals irresponsible. Between these two extremes society and the courts have been vibrating for a half-century; and a homicide was quite sure either to be convicted of murder in the first degree or acquitted; either to be condemned to death or declared free and innocent. The courts at present are inclined to recognize what physicians call degrees of insanity, and what jurists call degrees of responsibility. This will necessitate a modification of the laws relative to crime and a new category of degrees. Science, experience, prudence, are demanding the recognition of these new and numerous distinctions, and we are on the eve of a grand system of criminal jurisprudence which will outstrip all former achievements of lawmakers. The change is certain, but it will, of course, be gradual, and will scarcely keep pace with scientific knowledge. The treatises which have been published within the past thirty years, both in the English and other languages, are doing much to prepare the way for this systematic reform in criminal jurisprudence. Ray's Medical Jurisprudence of Insanity, Browne's Medical Jurisprudence of Insanity, and the present treatise of Mr. Wharton, are admirable contributions to the literature of this momentous and difficult subject. The present edition of Mr. Wharton's Treatise on Mental Unsoundness is the third; but the whole matter has been so thoroughly and completely re-arranged and rewritten and modified, to conform to the advanced state of the science of the jurisprudence of insanity, that it is really a new treatise. This work compares favorably with the "Criminal Law" and the "Conflict of Laws" of the distinguished jurist, and its exceptional importance will insure it additional success. A Treatise on the Law of Set-off, Recoupment and Counterclaim, by Thomas W. Waterman, 2d ed. New York: Baker, Voorhis & Co., 1872. No greater or more reliable commendation of Mr. Waterman's work on Set-off, Recoupment, Counterclaim and Reconvention could be bestowed than the profession have given it by rendering it necessary to publish a second edition at the end of three years. The subject of this treatise is one of the most technical and subtle of the law; and the author has redeemed from the chaos of scattered reports a systematic and well-arranged production which meets the wants of a large body of the profession. Although the tendency of modern legislation in the United States is to ignore the technical distinctions of the common law, and simplify the rules of pleading, yet it has thus far been found impracticable to so codify and define as to render a reference to the old distinctions unnecessary. In New York, Indiana, Ohio and California, the commonlaw distinctions between set-off, recoupment and counter-claim have been largely modified by statute In New York counter-claim is made to include everything which formerly was designated as set-off, recoupment, etc., legal or equitable, and the same may be said of those States which have adopted codes of procedure similar to that in New York. In Vermont, Illinois, and other States which retain the commonlaw practice, the old distinctions remain, not only in fact but in form; and a work of this character is especially desirable there. In Louisiana and Texas the French and civil law has, as formerly, an influence upon the pleading and practice; and the reconventio of the civil law is retained. Mr. Waterman has included in his treatise all the species of cross-actions, demands in reduction of damages, claims positive and negative, and all the modifications of the common law in respect to these in the several States which have special statutory regulations on the subject. By so doing, he has produced a work which is not only special, technical, critical and local, but also one that is general and universal, and as desirable for the lawyer in one State as in another. In the present edition are embraced more than a hundred new sections and several hundred additional cases; thus making the number of cases cited in this work over two thousand, a fact which is alone sufficient to demonstrate the importance, utility, and magnitude of the subject, and the industry and perseverance of the author. Mr. Waterman's treatise should receive the continued encouragement and patronage of the profession. COURT OF APPEALS ABSTRACT. ATTORNEY. Acting as broker. — If lawyers transact business as brokers, they are entitled to compensation as such, and cannot charge a counsel fee for the conversations had with their employers about the business, any more than persons who engage in the business of brokers only, unless there is an express contract to pay for such conversations. The law will not imply any such contract, from the fact that the party acts sometimes as a broker, and at other times practices as a lawyer. Walker v. The American National Bank. Opinion by Grover, J. COMMON CARRIER. 1. Transportation of cattle. Defendant received from plaintiff five car loads of cattle, to be transported from Erie to Buffalo, under a written agreement, by the terms of which plaintiff assumed all risks of injuries "from delays or in consequence of heat, suffocation or the ill effects of being crowded upon the cars." The agreement provided that plaintiff should load and unload the cattle at his own risk, the defendant furnishing assistance as required. An agent of the owner was to ride free, and take the care and charge of the stock. The cattle were in charge of such agent. At Dunkirk the train was delayed by a snow storm three days. The cattle could have been unloaded by constructing a platform. This defendant declined to do, and they remained in the cars twentyfour hours. In consequence thereof three of the cattle died and others were injured. Held, that under the contract the duty of defendant had respect simply to the transportation and not to the care of the cattle while in transitu. That the provision, as to loading and unloading, referred to the terminus of the transportation and not to an intermediate station, and defendant was not required to unload at Dunkirk or furnish facilities for so doing, that the injury was attributable to the negligence of plaintiff's agent, or at least there was contributory negligence on his part, and that plaintiff could not recover. Peckham, J., dissenting. Penn v. Buffalo and Erie Railroad Co. Opinion by Allen, J. 2. A common carrier of animals is not an insurer against injuries arising from their nature and propensities, and which could not be prevented by foresight, diligence and care. Where they are transported under a special agreement, the liability of the carrier is to be determined by the agreement. He is only liable for the performance of the duty undertaken thereby, or for some wrongful act, either willful or negligent. Ib. CONTRACT RESCISSION of action. 1. After a valid rescission of a contract of sale, on account of fraud on the part of the vendee, the right of action upon the contract is gone, and no subsequent act of the vendor alone can revive the contract or the right of action thereon. Where, therefore, the vendor has elected to avoid the sale, and has asserted his title to the property by bringing an action for conversion against a third person, into whose hands a portion of the goods sold have come, the mere bringing a subsequent action upon the contract, against the vendee. will not defeat the right of recovery in the first action. So also, the receipt by the vendor from the vendee of compensation in any form or upon any basis, for that portion of the goods which the latter has retained, will not affect the title to the residue, or the action pending for the conversion thereof. A settlement therefore with the vendee of the action, upon the contract of sale from which is expressly excluded that portion of the goods for the conversion of which the first action was brought, will not affect that action. So long as the settlement is confined to the portion of the goods retained by the vendee it is immaterial to the defendant in the first action, whether it is in the form of a payment as on a purchase, or of compensation for a conversion, nor is it material whether upon such settlement the vendor retains the original consideration received under the contract, or whether other compensation is substituted. It is not a revival of the old contract, but a new one different from and embracing only a part of the subject of the former. Grover, J., dissenting. Kinney v. Kiernan et al. Opinions by Rapallo and Grover, JJ. 2. As against a third person claiming under a fraudulent vendee, in order to establish a rescission if the contract of sale, it is not necessary to prove a return or offer to return any securities received thereon of the vendor refrains from the assertion of any title to those securities founded upon the original contract. Ib. 1. Sale and delivery: when title passes. This case has been heretofore before the general term, and will be found reported in 3 Albany Law Journal, p. 279. Upon the new trial then ordered by the general term, a verdict was rendered for plaintiff. The case is now on appeal from an order of special term granting another new trial. On August 30, 1867, plaintiff agreed to purchase of defendants fifty-six barrels of whiskey to arrive, at an agreed price, and paid $300 on account of the price. The whiskey was to come from Oneida county, and was to be delivered in bond at Warren's warehouse, Hunter's Point, and as soon as it was inspected, then the plaintiff was to pay the balance of the purchasemoney. After the inspection of the whiskey at the Hunter's Point warehouse, some disagreement arose between the parties as to the amount to be paid for it; the inspection at Hunter's Point showing some deficiency from the country gauge. The defendant claimed that the whiskey was sold at the country gauge, and plaintiff insisted that he was only to pay for what arrived at Hunter's Point. This dispute was never settled, and the plaintiff never completed the purchase nor attempted so to do, by tendering to the defendant the amount which he admitted to be due under his own version of the contract, nor was the property ever delivered to him by the defendant; it was both stored and bonded in the name of defendant. Defendant having subsequently sold the whiskey, this action is brought to recover damages for its conversion. Held, that no title to the whiskey passed, and therefore an action for conversion was not maintainable. The bill rendered by defendant, upon the face of which it is claimed that it is shown that the defendant thought the title to the whiskey passed on the 30th of August, the date of the agreement to purchase, cannot change the legal rights or status of the parties. It is entirely immaterial what the defendant thought in respect to the rights of the parties under the contract, unless it is shown that it was agreed between the parties that the title should pass at the time the contract was made, and that the whiskey was then at his risk. It is certain that if the whiskey had been destroyed after August 30, and before it was inspected at Hunter's Point, and a claim had been made by the defendant that notwithstanding its destruction the plaintiff was bound to pay for it, the plaintiff would have successfully resisted the claim upon the ground that until delivery the title did not pass. The case presents precisely the same questions as it did when heard by the court before, and the decision of the special term was in accordance with the decision upon the former appeal. The order must be affirmed. Fay v. Smith. Opinion by Brunt, J. CONTRACTS. Construction of contracts. By the agreement in question in this action, the defendants agree with plaintiff to enter into, and carry on business, etc., and to employ the plaintiff in said business, and to pay him, as a salary and compensation for his services, a sum which shall be equal to one-half of the net profits of said business, after deducting every expense and loss connected therewith, as follows: the sum of $3,000 yearly, and every year during the continuance of said agreement, in weekly installments at the rate of $3,000 per annum, and only at that rate for a shorter period than a year, and to pay any balance of said salary beyond said sum of $3,000 per year, if realized at the end and only at the end of each year, and if not then realized, whenever thereafter the same shall have been realized. The plaintiff agreed to devote his whole time and ability to said business, and all his information and knowledge to make the same profitable to defendants, to keep and render accurate accounts thereof; that he would not engage in any other business, and would accept as a compensation for his services, the provisions and payments as above mentioned. It was further agreed between the parties that if said business should prove profitable, etc., that it should continue for three years from July 1, 1869, unless sooner terminated as therein provided. The plaintiff worked for defendants in pursuance of said agreement from July 1 to Nov. 20, 1869, when he was discharged by them. He was paid $640, and the judgment herein was rendered for the balance alleged to be due him under said agreement. The said business was conceded to be uuprofitable, and for this reason plaintiff's right to recover is disputed, and the question now is, was his salary, to the extent of $3,000, independent of the profits of said business, as compensation fixed and to be paid in any event, or was the whole transaction a mere business venture on his part, dependent upon the realization of profits. Held, following the rule laid down in Blossom v. Griffin, 13 N. Y. 569, the question is, in view of all the surrounding circumstances and pre-existing relations between the parties, whether the plaintiff is not entitled to such a construction of the agreement as will sustain his right of action. The business engaged in, was that of "enameling and linen-finishing paper collars," to which plaintiff was to devote his exclusive time, knowledge, and ability. He was employed by defendants for this purpose. They did not engage to advance any capital, and were not required to devote any time or attention to the business. Unless we regard his compensation to the extent of $3,000 as fixed and certain, there would be no mutuality in the contract, nothing to offset plaintiff's knowledge of the business, and the exclusive devotion of his time and attention thereto. The fair interpretation of this agreement is this: the defendants, having confidence in plaintiff's skill and ability to manage said business successfully, and believing that it would realize an annual net profit of at least $6,000, employed him at a fixed compensation equal to one-half of said amount, the increase of which was made to depend upon the excess of profits. Coughtry v. Levine. Opinion by Larremore, J. (To be continued.) FOURTH DEPARTMENT. OCTOBER TERM, 1872. BONDING TOWNS. In February, 1872, a petition to bond the town of Leicester, in Livingston county, was duly presented to the county judge of said county, and thereafter commissioners were duly appointed to issue said bonds in aid of the construction of the R. U. & Pa. R. R. Co. Before the bonds of said town were issued, the R. U. & Pa. R. R. Co. was consolidated with the R. U. & Pa. Extension R. R. Co., and the Northern Extension R. R. Co., and the consolidation called the R. U. & Pa. R. R. Co. The commissioners afterward refused to issue the bonds of said town, on the ground that the petition did not authorize the issue of bonds to said consolidation. This was a motion to compel the commissioners to issue said bonds to said consolidated companies. Held, that the commissioners had no power to bind the tax payers of said town, except such as was derived from the petition, etc. That as the petition gave the name of the company, the location and route of the road, it controlled the commissioners, and they could not legally issue bonds for any other or different company or for any other or different route. That all subsequent acts of the legislature confirming the consolidation, and authorizing the issue to said consolidation were void. The R. U. & Pa. R. R. Co. v. Cuyler et al. Opinion by Mullin, P. J. CRIMINAL LAW. The plaintiff in error was indicted for robbery and larceny from the person. On the trial it was proved by the person robbed that at 3 o'clock P. M. he examined his pocket book and had in it $51 in money; that he saw it in his pocket book again during the evening; that he did not take it out, and that it was stolen about 10 o'clock the same evening. His evidence as to the possession of the money is uncontradicted. Held, that it being proved conclusively that the money was in the pocket book at 3 P. M., and there being no proof that it was lost, the presumption is that it was there when the pocket book was taken. If, therefore, the prisoner stole the pocket book, he stole the $51 in money also. The prisoner's counsel requested the court to charge the jury that the offense was petit larceny, unless the jury can safely say from the evidence, that the pocket book and its contents were worth more than $25. The court refused so to charge, and remarked, "that it is immaterial how much the pocket book contained." Held, that as it stood uncontradicted that the pocket book contained $51, the refusal of the judge to charge as requested, and his remark, "that it was immaterial how much it contained," though erroneous, did not and could not in any way injure the prisoner. The case does not show that any proof was given on the trial that whether the bills were genuine or that the corporations by which they were issued were incorporated or had any right to issue them, nor did the prisoner's counsel call the attention of the court or district attorney to the necessity of such proof until after the close of the evidence. He requested the court to charge the jury that there was not sufficient evidence to authorize the jury to find the prisoner guilty of larceny. This the court refused to charge. Held, that judgments "in criminal cases, except in capital cases, and cases in which the minimum of punishment is imprisonment for life, will not be reversed, except for such defects appearing on the face of the record as render the conviction illegal and void, as for erroneous rulings on the law to which exceptions were taken on the trial, and all contained in the bill of exceptions; that there may have been evidence given on the trial in reference to the genuineness of the bills not incorporated in the case. The refusal of the court to charge as above requested only implies that there was sufficient evidence, and if there was not, the prisoner's counsel should have objected to the want of proof as to genuineness, etc., on the trial. Higgins v. The People. Opinion by Mullin, P. J. (To be continued.) BANKRUPTCY LAW. NOTES OF RECENT DECISIONS. CHATTEL MORTGAGE. 1. A mortgage covering "a stock of lumber and moldings, and all renewals thereof from time to time," and other property, although void as to the lumber and moldings, may still be valid as to the other property. U. S. Dist. Ct., S. D. N. Y., In re Perrin and Hance, 7 N. B. R. 283. 2. Although the mortgage was recorded only the day before the petition in bankruptcy was filed, the evidence showed that the consideration did not pass until the mortgage was recorded. Held, that the transaction was an inchoate one, not consummated until the mortgage was recorded, but still in point of time, a unit; being marked by good faith, the consideration ought to be regarded as passing when the mortgage was recorded. The court further held that the proceeds of the sale of the property, other than moldings and lumber, must be applied on the amount due on the mortgage. Ib. PARTNERSHIP-SECRET PARTNERSHIP. Participation in the profits of a business is presumptive or primary proof that the participator is a partner in such business, and in the absence of other proof is sufficient evidence thereof, but such presumption may be overcome by showing that such profits were received by the party simply as wages for services performed, or interest for money loaned to the person carrying on such business. U. S. Dist. Ct., Oregon, In re Francis. PUBLICATION OF NOTICE. Where a statute requires a notice to be published once a week for four weeks, in order to a strict compliance therewith, an interval of seven days must intervene between such publication. Hence, a notice published on the eleventh, twenty-first and twentyseventh days of January, and on the first and tenth days of February, does not comply with the terms of the statute, and any proceedings based on such publication must fail on account of this irregularity. U. S. Dist. Ct., S. D. N. Y., In re King, 7 N. B. R. 279. REGISTER EXAMINATION. 1. The register has power to make the order, under section twenty-six of the bankrupt act, requiring the bankrupt or a witness to appear and be examined. U. S. Dist. Ct., N. D. N. Y., In re Pioneer Paper Company, 7 N. B. R. 250. 2. It is not necessary to apply to the court to obtain such order. Ib. 3. On such examination the bankrupt or witness may be examined fully, substantially as under a reference upon a creditor's bill, or in supplementary proceedings under the code. Ib. SUSPENSION OF PAYMENT. 1. An adjudication of bankruptcy will not be made solely on the fact that a promissory note contested by the maker has not been paid for more than fourteen days after it has become due. That is not a suspension of payment of commercial paper under the bankrupt act. U. S. Dist. Ct., E. D. N. Y., In re Mannheim. 2. An adjudication of bankruptcy cannot be had upon notes that were given merely as vouchers or memoranda, and which had no stamps upon them when given, or nothing to show that any stamps were to be put upon them by the maker thereof. Although payment was suspended upon said notes, in fact it was not such a suspension as the bankrupt law contemplates, for the reason that the maker claimed to have a good defense to their payment, and honestly believed that he was not legally bound to pay the notes until it should be so adjudged by a competent tribunal. U. S. Dist. Ct., S. D. N. Y., In re Charles S. Wescott et al., 7 N. B. R. 285. It appears from the annual report of the librarian of congress, that there are in that library an aggregate of 246,345 volumes and about 45,000 pamplets, being an increase from last year of 9,500 volumes. MARITIME LAW. NOTES OF RECENT DECISIONS. SALE OF CARGO BY MASTER. 1. Authority of: necessity for sale: communication with owner: telegraph: general cargo. -The authority of the master of a ship to sell the goods of the absent owner is derived from the necessity of the situation in which he is placed; and, consequently, to justify his thus dealing with the goods he must establish (1) a necessity for the sale; and (2) inability to communicate with the owner and obtain his directions. The Australasian Steam Navigation Company v. Morse, Priv. Co., 27 L. T. R. 357. 2. There is a "necessity " for the sale if, under the circumstances of the case, a sale is the best and most prudent thing to be done for the interest of the owner. Ib. 3. The possibility of communicating with the owner depends on the circumstances of each case, involving a consideration of the facts which create the urgency for an early sale; the distance of the port from the owners, the means of communication which exist, and the general position of the master in the particular emergency. Ib. 4. Such communication only needs to be made where an answer can be obtained, or there is a reasonable however, there is ground for such an expectation, every expectation that it can be obtained, before sale; where, endeavor, so far as the position in which he is placed will allow, should be made by the master to obtain the owner's instructions. Ib. 5. The master is bound to employ the telegraph as a means of communication, where it can usefully be done; but the state of the particular telegraph, the way in which it is managed, and the possibility of transmitting explanatory messages, are proper subjects to be considered in determining the question of the practicability of communication. Ib. 6. The fact that the master cannot communicate with all the owners of a general cargo, does not, of itself, justify him in selling without communication with any of the owners; but this fact, increasing the embarrassment of the master, is to be considered when an estimate of his conduct has to be formed. Ib. SALVAGE. 1. Collision: salvor to blame: right of owners to recover in respect of another vessel: employment of salvor. A vessel rendering assistance to another which she has injured in collision cannot claim salvage reward if the collision takes places by her default. The Glengaber, Adm., 27 L. T. R. 386. 2. The owners, master and crew of a vessel which renders assistance to a vessel injured by collision are not deprived of their right to salvage reward by the fact that some of the owners are also owners of another vessel by whose misconduct the collision takes place. Ib. 3. A vessel rendering salvage assistance is not deprived of her right to reward by the fact that she is employed by a vessel whose misconduct renders her employment necessary. Ib. 4. Salvage services were rendered by four steamers; one of the steamers had come into collision with the vessel salved, and was found to blame, and she rendered the principal services. The value of the property salved was £22,200. Held, that the three vessels not to blame were entitled to reward. The court awarded £310. Ib. |